Chambers v. Maroney
Chambers v. Maroney, 399 U.S. 42 (1970), was a United States Supreme Court case in which the Court applied the Carroll doctrine[1] in a case with a significant factual difference—the search took place after the vehicle was moved to the stationhouse. The search was thus delayed and did not take place on the highway (or street) as in Carroll.[2] After a gas station robbery, a vehicle fitting the description of the robbers' car was stopped. Inside were people wearing clothing matching the description of that worn by the robbers. They were arrested, and the car was taken to the police station where it was later searched.
| Chambers v. Maroney | |
|---|---|
 | |
| Argued April 27, 1970 Decided June 22, 1970 | |
| Full case name | Chambers v. Maroney, Correctional Superintendent |
| Citations | 399 U.S. 42 (more) 90 S. Ct. 1975; 26 L. Ed. 2d 419 |
| Case history | |
| Prior | 408 F.2d 1186 (3d Cir. 1969) (affirmed) |
| Court membership | |
| |
| Case opinions | |
| Majority | White, joined by Burger, Black, Douglas, Brennan, Stewart, Marshall |
| Concurrence | Stewart |
| Concur/dissent | Harlan |
| Laws applied | |
| U.S. Const. amend. IV | |
Opinion of the Court
The Court first held that the search could not be sustained as a search incident to arrest (SITA). It quoted at length from Carroll that a search of a movable vehicle is treated differently under the Fourth Amendment because the mobility of the vehicle alone can easily defeat the warrant requirement.[3] If there is probable cause to believe the vehicle contains criminal evidence and there exist exigent circumstances where the vehicle can be removed from the jurisdiction, a warrantless search would be reasonable.[4] It made no constitutional difference here that the search followed the seizure because the probable cause which developed on the street still existed at the station house (where the vehicle was impounded).[5] For this purpose, it is significant to note that the automobile exception and the SITA doctrine are quite different.
References
- See Carroll v. United States, 267 U.S. 132 (1925).
- Compare Preston v. United States, 376 U.S. 364 (1964), and Dyke v. Taylor Implement Mfg. Co., 391 U.S. 216 (1968), where the Court held that a search incident could not be conducted later at the stationhouse.
- Chambers v. Maroney, 399 U.S. at 48-49, quoting Carroll, 267 U.S. at 153-54.
- Chambers, 399 U.S. at 50-51: But the circumstances that furnish probable cause to search a particular auto for particular articles are most often unforeseeable; moreover, the opportunity to search is fleeting since a car is readily movable. Where this is true, as in Carroll and the case before us now, if an effective search is to be made at any time, either the search must be made immediately without a warrant or the car itself must be seized and held without a warrant for whatever period is necessary to obtain a warrant for the search. See also id. at 51 n. 9.
- Chambers, 399 U.S. at 52. Compare United States v. Edwards, 415 U.S. 800 (1974) (overruled on other grounds by United States v. Chadwick, 433 U.S. 1 (1977) and diverged from by California v. Acevedo, 500 U.S. 565 (1991) (a delayed seizure of clothing from an arrestee was not an unreasonable search), and United States v. Van Leeuwen, 397 U.S. 249 (1970) (delay of mail in transit to allow probable cause to develop).
Further reading
Chambers is discussed in:
- Note, 75 Dick L Rev 511 (1971);
- Note, 46 Ind L J 257 (1971);
- Comment, 47 Notre Dame Law 668 (1972);
- Note, 7 Tulsa L J 197 (1971);
- Note, 23 Vand L Rev 1370 (1970).
- Heisse, Warrantless Automobile Searches and Telephonic Search Warrants: Should the Automobile Exception be Redrawn?, 7 Hast Const L Q 1031 (1980).
External links
- Text of Chambers v. Maroney, 399 U.S. 42 (1970) is available from: Justia Library of Congress Oyez (oral argument audio)